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SUMMARY:Tw-tier tax systems and firms: evidence from Brazil - Dr Joana Nar
itomi (London School of Economics)
DTSTART;VALUE=DATE-TIME:20190612T113000Z
DTEND;VALUE=DATE-TIME:20190612T123000Z
UID:https://talks.ox.ac.uk/talks/id/c7f33da0-af73-45b0-bfca-bb1e200a2e88/
DESCRIPTION:The paper being presented uses novel administrative data on in
ter-firm trade linked to labour inputs from Sao Paulo\, Brazil\, to shed l
ight on implications of such dual systems for firm growth\, market competi
tion and production decisions.\nSpeakers:\nDr Joana Naritomi (London Schoo
l of Economics)
LOCATION:Saïd Business School (Boardroom in Main Building but report to
Main Reception and ask for Pauline Simpson)\, Park End Street OX1 1HP
URL:https://talks.ox.ac.uk/talks/id/c7f33da0-af73-45b0-bfca-bb1e200a2e88/
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DESCRIPTION:Talk:Tw-tier tax systems and firms: evidence from Brazil - Dr
Joana Naritomi (London School of Economics)
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SUMMARY:The effect of transfer price regulation and thin capitalization ru
les on host country welfare - Tom Gresik (University of Notre Dame)
DTSTART;VALUE=DATE-TIME:20190501T100000Z
DTEND;VALUE=DATE-TIME:20190501T113000Z
UID:https://talks.ox.ac.uk/talks/id/b427f486-c30b-44b2-9dcd-40a444ba3e1f/
DESCRIPTION:\nSpeakers:\nTom Gresik (University of Notre Dame)
LOCATION:Saïd Business School (Seminar Room 14\, Main Building but report
to reception and ask for CBT)\, Park End Street OX1 1HP
URL:https://talks.ox.ac.uk/talks/id/b427f486-c30b-44b2-9dcd-40a444ba3e1f/
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DESCRIPTION:Talk:The effect of transfer price regulation and thin capitali
zation rules on host country welfare - Tom Gresik (University of Notre Dam
e)
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SUMMARY:International Taxation in an Era of Digital Disruption: Analyzing
the Current Debate - Professor Itai Grinberg (Georgetown University Law Ce
nter)
DTSTART;VALUE=DATE-TIME:20190328T110000Z
DTEND;VALUE=DATE-TIME:20190328T123000Z
UID:https://talks.ox.ac.uk/talks/id/ed7c1d11-d54d-47fa-86dd-2299954967b6/
DESCRIPTION:The “taxation of the digital economy” is currently at the
top of the global international tax policymaking agenda. A core claim som
e governments are advancing is that user data or user participation in the
digital economy justifies a gross tax on digital receipts\, new profit at
tribution criteria\, or a special formulary apportionment factor in a futu
re formulary regime targeted specifically at the “digital economy.” J
ust a couple years ago the OECD undertook an evaluation of whether the dig
ital economy can (or should) be “ring-fenced\,” and concluded that it
neither can be nor should be. That conclusion is consistent with the find
ings of the European Commission High Level Expert Group on Taxation of the
Digital Economy.\n \nImportantly\, concluding that there should be no spe
cial rules for the digital economy does not resolve the broader question o
f whether the international tax system requires reform. The practical rea
lity appears to be that all the largest economies have come to agree eithe
r that a) there is something wrong with the taxation of the “digital eco
nomy\,” or b) there is something more fundamentally wrong with the struc
ture of the current international tax system given globalization and techn
ological trends. The IMF also strongly endorses the idea that fundamental
reform of the international tax system is necessary.\n \nCurrently four p
roposals for reforming the international tax system are being discussed at
the OECD. My paper (which predates the OECD consultation paper) is inten
ded as a ‘second best’ exploration of some of these ideas. First\, I c
onsider whether “user participation” justifies changing profit allocat
ion results in the digital economy alone. I conclude that applying the us
er participation concept in a manner that is limited to the digital econom
y is intellectually indefensible\; at most it amounts to mercantilist ring
-fencing. Moreover\, at the technical level user participation faces all
the same challenges as more comprehensive and principled proposals for rea
llocating excess returns among jurisdictions. Second\, I consider one suc
h comprehensive international tax reform idea\, loosely referred to by the
moniker “marketing intangibles.” This idea represents a compromise b
etween the present transfer pricing system and sales or destination-based
reforms to the transfer pricing regime. I conclude that splitting taxing
rights over “excess” returns between the present transfer pricing syst
em and a destination-based approach is complex\, creates new sources of po
tential conflict\, and requires relatively extensive tax harmonization. T
his conclusion applies equally to user participation and marketing intangi
bles. If such a mechanism were nevertheless pursued\, I suggest that a fo
rmulary system for splitting the excess return is the most manageable appr
oach. Third\, I consider “minimum effective taxation” ideas. I concl
ude that\, as compared to the other two policy options discussed herein\,
minimum effective taxation provides a preferable path for multilateral coo
peration. \n \n\n\nSpeakers:\nProfessor Itai Grinberg (Georgetown Univer
sity Law Center)
LOCATION:Saïd Business School (Boardroom\, Dean's Suite\, )\, Park End St
reet OX1 1HP
URL:https://talks.ox.ac.uk/talks/id/ed7c1d11-d54d-47fa-86dd-2299954967b6/
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DESCRIPTION:Talk:International Taxation in an Era of Digital Disruption: A
nalyzing the Current Debate - Professor Itai Grinberg (Georgetown Universi
ty Law Center)
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